interests were particularly high because this was a search for weapons and a wanted gang member resided on the premises. The Court acknowledged that the duration of detention does impact the balancing, but held that the two-to-three hour detention in handcuffs did not outweigh the government's safety interest. The Court's decision in Muehler v. Mena has been criticized by civil rights attorney Amir H. Ali, in his contribution to the Harvard Civil Rights Journal. Ali commented that the decision arguably represents a serious expansion of the personal intrusion that had been permitted in Michigan v. Summers''. He went on to say that had the Court undergone a balancing of the totality of the circumstances, it would have been hard to justify the Mena's prolonged detention in handcuffs. In addition, the Muehler Court's one sentence justification—“this case involved the detention of four detainees by two officers during a search of a gang house for dangerous weapons”—set the bar remarkably low. Ali also emphasized, "the Court did not address the fact that, although two officers were on guard, there were actually eighteen officers on the scene, or the concurring Justices' observation that 'this 5-foot-2-inch young lady posed no threat to the officers.'" References External links Petitioner Brief in Muehler v. Mena ACLU Amicus Brief in Muehler v. Mena United States Supreme Court cases United States Fourth Amendment case law 2005 in United States case law United States Supreme Court cases of the Rehnquist Court